Date: 09/14/2000 8:02 AM
Subject: Reference File No. S7-13-00
Jonathan G. Katz, Secretary
Securities and Exchange Commission
Re:File # S7-13-00 Proposed Non-Audit Services changes
Dear Mr Katz:
I write to express my opposition to the proposed SEC
rule change to restrict Non-Audit Services a CPA can
provide to a client when performing Audit Services. I
believe this proposal would reduce independence in
audit services instead of increasing independence.
The performance of audit services is an extremely
competitive service. Unlike years ago the profit
margin for these services is very small. Without the
revenues provided by Non-Audit Services CPA firms
could not attract the talent and knowledge required in
the modern business climate. Transactions by large
multi-national corporations are very complex and
require knowledge outside the normal financial
statements. Under the proposed plan CPA Firms
conducting audits of these corporations would not be
able to attract the talent required to understand
complex financing, recognize risk or the financial
implications.
There is no evidence that the providing of Non-Audit
Services to Audit clients has reduced independence.
Indeed I believe that providing Non-Audit Services
enhances audit quality. The CPA becomes more
knowledgeable about client operations through the
provision of other services. This additional knowledge
improves the quality of audit services.
The proposal under consideration is ill advised. The
public accounting community has an excellent
self-regulation system. In addition shareholders are
protected against audit failure through access to the
courts.
I urge the rejection of this proposal.
Bernard G. Buerger,CPA
1095 Nimitzview, Suite 302
Cincinnati, OH 45230